April 21, 2017–Public safety 911 officials complained in recent conversations with representatives of the FCC’s Public Safety and Homeland Security Bureau about what they said were inadequate notifications after a March 8 nationwide AT&T, Inc., 911 outage that impacted wireless customers.Last month, the Public Safety Bureau issued a public notice seeking comments on the bureau’s investigation of two AT&T 911 outages that month (TR Daily, March 23). The bureau’s investigation involves the widely reported outage of AT&T Mobility’s voice-over-LTE (VoLTE) 911 service on March 8, and what appears to be a lesser VoLTE 911 service outage on March 11.
In an ex parte filing in PS docket 17-68 reporting on a phone conversation with bureau staff, National Association of State 911 Administrators (NASNA) Executive Director Evelyn Bailey said, “In this particular outage, many PSAPs were notified even though they were not actually affected. For instance, PSAPs in Iowa were notified of the outage, but not one of them was affected (that fact was not clear at the time). The result was a flurry of unnecessary activity as people leapt into action to try to get information and determine how to respond. Iowa’s 911 administrator observed that if he had issued a public notice about the outage, and then had to retract it upon learning that his state had not been affected, it would have diminished the credibility of the program and the public’s confidence in the 911 system. It is very important that PSAPs – and state 911 administrators – be able to rely on the accuracy of the outage notification. The affected entity should target its notifications to those PSAPs that are actually affected by the outage. Scattershot notifications cause unnecessary alarm and waste of resources when there is no actual outage.”
The filing also said that the parties in the conversation discussed “whether there would be potential benefit from PSAPs receiving notification from more than one service provider. I stated that there was no potential benefit and that multiple notifications would likely cause confusion and diffuse the message. NASNA members would prefer that the service provider who is ultimately responsible, i.e., the 911 system service provider or prime contractor, be the one to deliver the outage notification on behalf of itself and/or its service partners.”
Ms. Bailey also said she “said that the 911 system service provider should contact the state 911 administrator in addition to the PSAPs. There is an important reason for this: some state 911 programs are directly responsible for the 911 system, even in the legacy 911 environment. If the state is the responsible party, but the PSAP receives the notification, the PSAP may not know what to do with the information they have received from the service provider.”
The parties also discussed “whether the affected provider should be the one to issue … notifications [to the public] and give the public an alternative number to call in each PSAP jurisdiction. I said that I did not think PSAPs (or state 911 administrators where appropriate) would want to relinquish control of the message to the public,” Ms. Bailey said in the filing. “One reason is because of the inconsistent nature of notifications that came, in this particular outage, from AT&T or its service partners, i.e., notifications were issued in places that were not affected. In addition, if the provider unilaterally informed the public to call an alternative number without the PSAPs’ knowledge, a serious public safety issue could result. Ten-digit numbers are often answered by administrative staff who are not trained to handle emergency calls. It would be a potentially serious problem if the ten-digit line(s) at a PSAP started to ring with live emergency calls and the PSAP was not aware of the outage and the instructions the 911 service provider had issued to the public.”
“When asked about text-to-911, I said that some states reported that text-to-911 continued to work, while others said that it did not. Where available, text-to-911 reassures people that they still have access to the PSAP and provides superior access over a ten-digit administrative line during an emergency,” the filing said.
In another ex parte filing reporting on a phone conversation with bureau staff, Dana Wahlberg, 911 program manager for the state of Minnesota, said that Comtech Telecommunications Corp., a 911 solutions provider whose customers include AT&T, notified some PSAPs in her state about the March 8 outage “with an ambiguous email stating that Comtech has identified a potential impairment affecting your PSAP stating AT&T calls may be impacted.” The e-mails were sent about five hours after the outage began, she said.
“Although I am confident the FCC mandated reporting process is well-intended, our experiences with it in MN have been extremely challenging,” Ms. Wahlberg added. “The notifications are not timely, they are not consistently reaching the correct people, and they are extremely vague. PSAP notification in real time of a single carrier experiencing an issue creates more problems than it solves. There needs to be a balance between timely notification and reliable notification. In the case of the AT&T outage, we had neither.”
The filing added that “the FCC, 9-1-1 service providers, 9-1-1- authorities, and PSAPs should reach an agreement on what circumstances warrant a notification. Subsequently, in an outage, it should be the 9-1-1 service provider(s) in each state who should be notified and be responsible for alerting the affected PSAPs and assisting in the public notification process.”
In another ex parte filing reporting on a conversation with bureau staff, Julie Righter Dove of the Lincoln Communications Center in Lincoln, Neb., said she “was never notified by a telecommunications entity of the outage. She saw on Facebook, at approximately 7:30 PM CST, that AT&T was experiencing issue with their 911 services. She used her personal phone, serviced by AT&T to place a call to AT&T, and did not reach the PSAP.”
She said that a 30-minute outage should be the threshold for reporting purposes, and “that notification directly from the carrier is preferred because they tend to have more information regarding the network and geographical scope, as well as information regarding the repair timeline. The notification should be simple, and should only inform the PSAP if the service is or is not working.” —Paul Kirby, firstname.lastname@example.org